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Georg, Jim, John and Ron, Thank you for your comments. I was hoping to encourage a discussion of the important issue of the application of the updated patent policy to “work in process” at IEEE-SA, and so I have. For convenience I have cut and pasted all the comments
received so that they are all in the same e-mail thread. I’ll respond to the comments in the order received: Georg Nolte (Panasonic) The point about retroactivity suggests that perhaps I did not explain my proposal clearly enough. It would have been very simple to draft a proposal that really
did impose retroactive obligations on submitters of LoAs for IEEE standards initiated before the effective date of the updated patent policy. I am trying hard to avoid doing so. I am focused on removing uncertainty regarding what patent policy applies
prospectively. As stated in my November 11 submission, IEEE-SA should promote clarity regarding which version of the patent policy text applies to which standards development effort, and avoid the situation in which different LoA submitters believe
themselves to be bound by different texts. So that working group participants have the benefit of clarity on the question of what text applies, I’m trying to identify a clear line: if an LoA was submitted as to a PAR that proposes and amendment to an IEEE-SA standard or proposes
a new standard, and that PAR was approved after the date of an updated policy text, an LoA submitter is free to declare that it is no longer bound by a previously submitted LoA. That submitter may submit a new LoA that will apply prospectively to the new
amendment or the new standard. If it does not do so, the updated text applies, but only prospectively, as to the PAR that began after the effective date of the updated text.
You also raise the concern that a submitter of an LoA would miss the chance to withdraw (again, prospectively only) its previously-submitted LoA. I certainly agree that IEEE-SA would want to use existing means of communicating with individuals
and companies active in standards development at IEEE-SA to promote awareness of updates in the patent policy. As to submitters that are no longer in business, if a patentee that submitted an LoA no longer exists, why would the patentee be concerned with
an update to the patent policy text? Ron Katznelson Like Georg, Ron focuses his comment on the concern that my proposal would apply retroactively. I have addressed that concern in my response to Georg. I do not view my proposal as creating retroactive obligations. I propose to give the
submitter of an LoA that was not specific to a particular PAR approved on or after March 15, 2015 the opportunity to remove any doubt regarding whether the policy would or would not apply retroactively by withdrawing (again, prospectively only) its earlier
LoA. If it does not avail itself of that opportunity, then the updated policy text would apply to new standards and amendments to existing standards resulting from PARs approved on or after March 15, 2015.
Jim Harlan I appreciate Jim’s reminder regarding the December 15, 2015 tweaks to the March 15 text. Jim’s point reminds us that the IEEE-SA patent policy is a living document; just as it has been revised several times in the last ten years, it may
be revised again in the future. Of course, if previously submitted LoAs apply to new PARs forever, then over time the number of different patent policy texts applicable to one or more participants in a particular IEEE-SA standards development effort will
continually increase. I did not understand Jim’s concern regarding new baseline texts. My proposal focuses on the date of PAR approval because it is a certain date, and can be tracked within IEEE-SA.
John Kolakowski (Nokia) I have responded above to John’s point regarding retroactivity, which, as John notes, echoes the point made earlier by Georg Nolte. On John’s point regarding what I am proposing, I am proposing a high-level solution to the lack of clarity
that exists today. I foresee that implementation that would be implemented through (at least) a change to Ops Manual Section 6.3.4, so that it is clear that an LoA submitter can withdraw (again, prospectively only) an LoA it previously submitted to “opt
out” of a change to the patent policy text. Making that revision is important so that submitters can limit the effect of previously submitted LoAs that were not limited to a specific PAR. ------ The only goal of my proposal is to provide clarity regarding what patent policy text applies to work begun at IEEE-SA on or after March 15, 2015. The proposal does so by choosing a certain and visible event, the approval of a PAR, and
applying the updated policy text to all standards resulting from PARs approved on or after March 15, 2015. Anticipating concerns with retroactivity, it provides anyone that submitted an LoA that would otherwise cover a standard resulting from a PAR approved
on or after March 15, 2015 with a chance to “opt out” of the updated policy text by submitting a new LoA to cover new PARs. I recognize that different companies had different positions on the wisdom of the updates to the IEEE-SA patent policy text. For the good of IEEE-SA’s important standards development work, supporters and opponents of the updates should
stop re-fighting old battles and make the current policy work. Of course, the patent policy text changed previously (for example, the change that became effective in April 2007 that imposed stricter patent disclosure obligations) and will likely change again in the future. Ironically, even reverting
to the pre-March 15, 2015 text, as Georg Nolte advocates, would not resolve the question of what LoA applies to work in process on the date new text is adopted. Indeed, it would only introduce another patent policy text that existed at a point in time and
which LoA submitters might seek to apply in the future. I hope that my proposal will be accepted in the spirit in which it is intended. Participants in standards development benefit from clarity regarding licensing intentions. That is the only goal I am trying to achieve. Hopefully, whatever
view one has of the 2015 updates, we share that goal. I look forward to the discussion at the PatCom meeting on Monday. Best regards, Gil Ohana ---------- Forwarded message ---------- From: "Kolakowski, John (Nokia - US/Herndon)" <john.kolakowski@xxxxxxxxx> PatCom members and interested participants, I write for Nokia Technologies, Nokia Networks and Alcatel-Lucent (collectively, “Nokia”) to indicate
formal agreement with, and support of, the arguments raised by Panasonic against the concepts set forth in Gil Ohana’s November 11, 2016 submission to the PP-Dialog listserv. In addition, I make these additional points: 1. Letters
of Assurance are of course contractual commitments between the patent holder and IEEE that have as third party beneficiaries the users of the standards. What is proposed here, as noted by Panasonic, is retroactive application of terms and conditions by one
party to the contractual commitment to the other party. As far as I’m aware, this would not be permitted under the contract laws of any jurisdiction. That one would be “invited” to withdraw the prior LoA and submit a “new” one under the current policy would
not matter. The original LoA submission was made by the patent holder under the terms and conditions that governed at the time when the technology was incorporated into a standard under development. If IEEE wishes to change the terms of that deal, then it
must either obtain the Submitter’s consent or find alternative technology – the Submitter cannot be penalized for allowing IEEE to use its technology but then having IEEE later change the conditions under which the permission was provided. Indeed, IEEE has
in the past made it clear that its new patent policy does not retroactively amend previously accepted LoAs, and Gil acknowledges the need to avoid retroactive amendment. However, in our view, adoption of a new (PAR-based) approach does not simply “add clarity”
(as Gil suggests). Rather, it has substantive effect on previously submitted and accepted LoAs, which themselves make no mention of PARs and which were submitted at a time when PARs were not mentioned in the patent policy at all. 2. It
is unclear exactly what Gil proposes. Is it a further addition to the proposed language in “Possible Addition to the Patent Slides for Standards Development Meetings of the FAQs” that is to be discussed under Agenda Item 5.2 at Monday’s PatCom meeting? Is
it a substantive change elsewhere in the Patent Slides, FAQs, or IPR Policy? Clarification is needed so all can better know the potential ramifications. As such, I would expect that any decisions made by the PatCom on Monday concerning this item 6.1 would
be at most a decision to continue discussion at future meetings by which time more information on intentions will have been provided. Regards, John Kolakowski ------------------------------------------------------
From: "Harlan, James I" <Jim.Harlan@xxxxxxxxxxxxxxxx> Dear All- In addition to Georg’s comments & concerns that I support, I believe Gil’s suggested PAR-based approach, setting aside for a moment any breach in legal obligations, also places too much burden on the Working Group chairs. Gil has suggested
that WG Chairs consider asking for “new LoAs when an accepted LoA pre-dates the text of the current policy,” and cites the March 15, 2015 patent policy. To begin, I would like to remind Gil the current IEEE-SA Standards Board Bylaws, to which the Patent Policy
is located at Sect 6, is dated December 2015 that was amended since the March 2015 policy “to remove the words ‘(for the purposes of licensing information)’ from Section B of the LOA form.” (See,
http://standards.ieee.org/develop/policies/bylaws/sb_bylaws.pdf and
https://standards.ieee.org/about/sasb/resolutions.html) As a practical matter, it should also be noted, when a PAR is created, it will have “Incorporated Baselines” as noted here:
http://www.ieee802.org/11/Reports/802.11_Timelines.htm. It sounds like Gil is suggesting that the WG chairs should then seek LoAs for each of the Incorporated Baselines pertaining to a new Working Group, should the prior-accepted LoAs pre-date the text of the current patent policy. As an example, for TGax, PAR Approval date of 27 March 2014: ·
TGax has incorporated baselines of 802.11REVmc, 802.11ai, 802.11ah, 802.11aq, 802.11ak, & 802.11aj; ·
802.11REVmc has incorporated baselines 802.11-2012, 802.11ae-2012, 802.11aa-2012, 802.11ad-2012, 802.11ac-2012, & 802.11af-2013; and ·
802.11-2012 has incorporated baselines 802.11-2007, 802.11k-2008, 802.11r-2008, 802.11y-2008, 802.11w-2009, 802.11n-2009, 802.11p-2010, 802.11z-2010, 802.11v-2011, 802.11u-2011 & 802.11s-2011. So, for TGax, the WG Chair would have to seek LoAs for 21 prior incorporated baselines? Then for TGay (PAR Approval date of 26 Mar 2015), that WG Chair would have to seek 22 new LoA’s according to Gil’s PAR-based approach if a prior-accepted
LoA pre-dates the text of the current policy (Dec 2015)? And for any new Working Group created post December 2015, the chair would have to seek LoAs from 23 incorporate baselines, from my understanding of Gil’s PAR-based approach that seems not only unworkable
from a process perspective, but from a resource perspective. I look forward to seeing y’all next week. Sincerely, Jim Harlan • Director, Standards & Competition Policy • InterDigital, Inc. 515 C St NE, Washington, DC 20002 • T: +1 202-349-1713 •
Jim.Harlan@xxxxxxxxxxxxxxxx ---------------------------------------------- Greg, You make excellent points. Your charitable characterization of Gil’s proposal, however, misses the basic flawed legal premise of his proposal – that IEEE-SA should breach the contract with legacy SEP holders.
The contract involves patent holders’ agreement to pledge SEPs under the specific terms of the previous patent policy, terms which IEEE-SA
accepted and is therefore legally bound by. Gil’s proposal is that IEEE-SA breach its obligations under those contract to compel those legacy SEP holders to LOA terms they never agreed to – i.e.,
unilaterally reopen the contract to new terms. It is of no moment that there might have been “work in progress” pertaining to the SEPs that were pledged under the previous patent policy. That “work in progress” created neither express nor implied
obligations by the SEP holders to be bound by terms other than those they agreed to in the legacy LOAs. To take Gil’s proposal to its logical equitable conclusion, if IEEE-SA were to
reopen these legacy LOA submitters’ rights and obligations, the only way it can lawfully do so is through a
bilateral reopening which would also permit the legacy SEP holders to withdraw their previous LOA commitments altogether without any substitution.
I do not think IEEE-SA wants to do that. Best regards, Ron ------------------------------------------------------- Ron D. Katznelson, Ph.D. President, Bi-Level Technologies 1042 N El Camino Real, Suite B-250 Encinitas, CA 92024 Office: 760 753-0668 Email:
ron@xxxxxxxxxxxxxxx Selected Works:
http://works.bepress.com/rkatznelson From: Georg Nolte [mailto:Georg.Nolte@xxxxxxxxxxxxxxxx]
Dear Dave, (Gil, and all PP-Dialog members) I'm writing in reply to Gil's email below. As far as I understand his email (Gil: please correct me if I got you wrong), Gil proposes to "retroactively" change existing LoAs. His proposal that "... PARs approved on or after March 15, 2015 would be governed by the updated policy text." And that "This would be true even if the patentee that submitted an LoA accepted before March 15, 2015 claims that the patent is within the scope of that LoA." But this proposal results in patents being declared under the old Patent Policy (pre 15.03.2015) will be governed by the new Patent Policy! This is not just totally unacceptable, but also in contradiction to the Business Review Letter (BRL) by Renata Hesse (see PDF available at https://www.justice.gov/atr/response-institute-electrical-and-electronics-engineers-incorporated)
[note that there is an error in the web page text; use the PDF!] as that BRL states that: "the Department offers no statement regarding its intentions concerning the application of the Update retroactively to previously submitted LOAs.(55)" with footnote 55 being: "(55) Request, supra note 1, at 19 (the revised Policy 'does not retroactively amend previously Accepted Letters of Assurance.')." In addition the BRL request letter also states in its footnote 33 that: "IEEE has publicly stated that it does not seek to amend retroactively the terms of any previously submitted Letter of Assurance, ...". Again, Gil's proposal is inconsistent with the BRL request from the IEEE to the DoJ and out of scope of the received BRL from the DoJ. Also his suggestion to give the patentee a 'grace period' to withdraw the LoA is not acceptable either. And this is actually (at least) for two reasons. He suggests that: "... within a reasonable time after the approval of a new PAR, [the patentee may] choose to withdraw that previously accepted LoA and substitute a new accepted LoA without being subject to a continuing commitment to license under the previous LoA under the current Operations Manual 6.3.4." Reasons why this is not acceptable: 1) No accepted LoA might ever be withdrawn (at least not if there were SEPs included at any time) and 2) even a "reasonable time" is void if a company that gave the LoA does not exist anymore, or does not get any notice (in whatever form) that such a "change" for their LoA might happen. Again, the proposed change does not match with current practice and understanding and will create even more confusion among IEEE participants and implementers. Besides that, his sentence "One troubling issue raised by the potential application of different patent policy texts to the same standards development effort is that different participants will be participating under different versions of the patent policy text." is exactly what IEEE-SA created with the change of its Patent Policy: there are now LoAs that have been submitted and are governed by quite different Patent Policies. To remove any confusion caused by the coexistence of LoAs governed by different Patent Policies, I propose another (simple) solution: just change back to old Patent Policy! I trust that you (and the whole PatCom) will give this email and the concerns raised herein due consideration in your meeting next week, for which I wish you all the best. Kind regards, Georg Mr. Georg NOLTE Patent Representative Panasonic R&D Center Germany GmbH Monzastr. 4c 63225 Langen Germany Office: +49.6103.766.131 Mobile: +49.172.79.72.744 From: Gil Ohana (gilohana) [mailto:gilohana@xxxxxxxxx]
Hi Dave,
Thank you for circulating the agenda. I wanted to propose an expansion of the discussion of Agenda Item 5.2. The current agenda item involves the addition of FAQ text to suggest to Working Group chairs that they consider asking for a
new LoA when an Accepted LoA pre-dates the effective date of the text of the patent policy (currently, March 15, 2015). I agree with the proposal. I am concerned, however, that it does not resolve the uncertainty that has existed since March 15, 2015 regarding
the applicability of the updated policy text to “work in process” – i.e. standards development efforts that were ongoing on March 15, 2015, and even standards development that began after March 15, 2015, but which arguably are within the scope of LoAs accepted
before March 15, 2015. In its resolution approving the “Draft 39” text that became the text of the updated patent policy, the Standards Association Standards Board of Governors (resolution dated December 2014, available here:
https://standards.ieee.org/about/bog/resolutions.html) provided for the March 15, 2015 effective date for the updated policy tex. However, IEEE-SA but did not expressly address the question
of the application of the updated policy text to “work in process”. As Chuck Adams noted at the June 2016 PatCom meeting questions have arisen regarding the application of the updated policy text to “work in process”. One troubling issue raised by the potential
application of different patent policy texts to the same standards development effort is that different participants will be participating under different versions of the patent policy text.
The proposal under Agenda Item 5.2 helpfully calls the attention of Working Group participants to the possibility that the submitter of a pre-update LoA may be relying on an LoA submitted before the effective date of the updated patent
policy text. However, IMHO more is needed to provide clarity and create a “level playing field” for participants in IEEE-SA standards development. Specifically, PatCom needs to draw a bright line identifying what standards development activities are covered
by the updated text. One approach would be to look at the date on which the PAR governing the creation of a standard, amendment, or revision for which a patent may be essential. The declaration and licensing of patents essential to standards developed based
on PARs approved on or after March 15, 2015 would be governed by the updated policy text. This would be true even if the patentee that submitted an LoA accepted before March 15, 2015 claims that the patent is within the scope of that LoA.
The PAR-based rule both avoids retroactive application of the patent policy and provides certainty to participants regarding which patent policy text governs which IEEE-SA standards development effort.
To anticipate questions regarding the interplay between the PAR-based approach to the coverage of the updated policy text and Operations Manual 6.3.4, it should be clear that a patentee that has submitted a previously accepted LoA that
covers patents essential to a standard created under a PAR approved after the effective date of a by-law change may, within a reasonable time after the approval of a new PAR, choose to withdraw that previously accepted LoA and substitute a new accepted LoA
without being subject to a continuing commitment to license under the previous LoA under the current Operations Manual 6.3.4. I look forward to discussing this proposal at the December meeting. Best regards, Gil Ohana From: Kolakowski, John (Nokia - US/Herndon) [mailto:john.kolakowski@xxxxxxxxx]
PatCom members and interested participants, I write for Nokia Technologies, Nokia Networks and Alcatel-Lucent (collectively, “Nokia”) to indicate formal agreement with, and support of, the arguments raised
by Panasonic against the concepts set forth in Gil Ohana’s November 11, 2016 submission to the PP-Dialog listserv. In addition, I make these additional points: 1.
Letters of Assurance are of course contractual commitments between the patent holder and IEEE that have as third party beneficiaries the users of the standards. What is proposed
here, as noted by Panasonic, is retroactive application of terms and conditions by one party to the contractual commitment to the other party. As far as I’m aware, this would not be permitted under the contract laws of any jurisdiction. That one would be
“invited” to withdraw the prior LoA and submit a “new” one under the current policy would not matter. The original LoA submission was made by the patent holder under the terms and conditions that governed at the time when the technology was incorporated into
a standard under development. If IEEE wishes to change the terms of that deal, then it must either obtain the Submitter’s consent or find alternative technology – the Submitter cannot be penalized for allowing IEEE to use its technology but then having IEEE
later change the conditions under which the permission was provided. Indeed, IEEE has in the past made it clear that its new patent policy does not retroactively amend previously accepted LoAs, and Gil acknowledges the need to avoid retroactive amendment.
However, in our view, adoption of a new (PAR-based) approach does not simply “add clarity” (as Gil suggests). Rather, it has substantive effect on previously submitted and accepted LoAs, which themselves make no mention of PARs and which were submitted at
a time when PARs were not mentioned in the patent policy at all. 2.
It is unclear exactly what Gil proposes. Is it a further addition to the proposed language in “Possible Addition to the Patent Slides for Standards Development Meetings of
the FAQs” that is to be discussed under Agenda Item 5.2 at Monday’s PatCom meeting? Is it a substantive change elsewhere in the Patent Slides, FAQs, or IPR Policy? Clarification is needed so all can better know the potential ramifications. As such, I would
expect that any decisions made by the PatCom on Monday concerning this item 6.1 would be
at most a decision to continue discussion at future meetings by which time more information on intentions will have been provided. Regards, John Kolakowski From: Georg Nolte [mailto:Georg.Nolte@xxxxxxxxxxxxxxxx]
Dear Dave, (Gil, and all PP-Dialog members) I'm writing in reply to Gil's email below. As far as I understand his email (Gil: please correct me if I got you wrong), Gil proposes to "retroactively" change existing LoAs. His proposal that "... PARs approved on or after March 15, 2015 would be governed by the updated policy text." And that "This would be true even if the patentee that submitted an LoA accepted before March 15, 2015 claims that the patent is within the scope of that LoA." But this proposal results in patents being declared under the old Patent Policy (pre 15.03.2015) will be governed by the new Patent Policy! This is not just totally unacceptable, but also in contradiction to the Business Review Letter (BRL) by Renata Hesse (see PDF available at https://www.justice.gov/atr/response-institute-electrical-and-electronics-engineers-incorporated)
[note that there is an error in the web page text; use the PDF!] as that BRL states that: "the Department offers no statement regarding its intentions concerning the application of the Update retroactively to previously submitted LOAs.(55)" with footnote 55 being: "(55) Request, supra note 1, at 19 (the revised Policy 'does not retroactively amend previously Accepted Letters of Assurance.')." In addition the BRL request letter also states in its footnote 33 that: "IEEE has publicly stated that it does not seek to amend retroactively the terms of any previously submitted Letter of Assurance, ...". Again, Gil's proposal is inconsistent with the BRL request from the IEEE to the DoJ and out of scope of the received BRL from the DoJ. Also his suggestion to give the patentee a 'grace period' to withdraw the LoA is not acceptable either. And this is actually (at least) for two reasons. He suggests that: "... within a reasonable time after the approval of a new PAR, [the patentee may] choose to withdraw that previously accepted LoA and substitute a new accepted LoA without being subject to a continuing commitment to license under the previous LoA under the current Operations Manual 6.3.4." Reasons why this is not acceptable: 1) No accepted LoA might ever be withdrawn (at least not if there were SEPs included at any time) and 2) even a "reasonable time" is void if a company that gave the LoA does not exist anymore, or does not get any notice (in whatever form) that such a "change" for their LoA might happen. Again, the proposed change does not match with current practice and understanding and will create even more confusion among IEEE participants and implementers. Besides that, his sentence "One troubling issue raised by the potential application of different patent policy texts to the same standards development effort is that different participants will be participating under different versions of the patent policy text." is exactly what IEEE-SA created with the change of its Patent Policy: there are now LoAs that have been submitted and are governed by quite different Patent Policies. To remove any confusion caused by the coexistence of LoAs governed by different Patent Policies, I propose another (simple) solution: just change back to old Patent Policy! I trust that you (and the whole PatCom) will give this email and the concerns raised herein due consideration in your meeting next week, for which I wish you all the best. Kind regards, Georg Mr. Georg NOLTE Patent Representative Panasonic R&D Center Germany GmbH Monzastr. 4c 63225 Langen Germany Office: +49.6103.766.131 Mobile: +49.172.79.72.744 From: Gil Ohana (gilohana) [mailto:gilohana@xxxxxxxxx]
Hi Dave, Thank you for circulating the agenda. I wanted to propose an expansion of the discussion of Agenda Item 5.2. The current agenda item involves the addition of FAQ text to suggest to Working
Group chairs that they consider asking for a new LoA when an Accepted LoA pre-dates the effective date of the text of the patent policy (currently, March 15, 2015). I agree with the proposal. I am concerned, however, that it does not resolve the uncertainty
that has existed since March 15, 2015 regarding the applicability of the updated policy text to “work in process” – i.e. standards development efforts that were ongoing on March 15, 2015, and even standards development that began after March 15, 2015, but
which arguably are within the scope of LoAs accepted before March 15, 2015. In its resolution approving the “Draft 39” text that became the text of the updated patent policy, the Standards Association Standards Board of Governors (resolution dated December 2014,
available here: https://standards.ieee.org/about/bog/resolutions.html)
provided for the March 15, 2015 effective date for the updated policy tex. However, IEEE-SA but did not expressly address the question of the application of the updated policy text to “work in process”. As Chuck Adams noted at the June 2016 PatCom meeting
questions have arisen regarding the application of the updated policy text to “work in process”. One troubling issue raised by the potential application of different patent policy texts to the same standards development effort is that different participants
will be participating under different versions of the patent policy text. The proposal under Agenda Item 5.2 helpfully calls the attention of Working Group participants to the possibility that the submitter of a pre-update LoA may be relying on an LoA submitted
before the effective date of the updated patent policy text. However, IMHO more is needed to provide clarity and create a “level playing field” for participants in IEEE-SA standards development. Specifically, PatCom needs to draw a bright line identifying
what standards development activities are covered by the updated text. One approach would be to look at the date on which the PAR governing the creation of a standard, amendment, or revision for which a patent may be essential. The declaration and licensing
of patents essential to standards developed based on PARs approved on or after March 15, 2015 would be governed by the updated policy text. This would be true even if the patentee that submitted an LoA accepted before March 15, 2015 claims that the patent
is within the scope of that LoA. The PAR-based rule both avoids retroactive application of the patent policy and provides certainty to participants regarding which patent policy text governs which IEEE-SA standards development
effort. To anticipate questions regarding the interplay between the PAR-based approach to the coverage of the updated policy text and Operations Manual 6.3.4, it should be clear that a patentee that
has submitted a previously accepted LoA that covers patents essential to a standard created under a PAR approved after the effective date of a by-law change may, within a reasonable time after the approval of a new PAR, choose to withdraw that previously accepted
LoA and substitute a new accepted LoA without being subject to a continuing commitment to license under the previous LoA under the current Operations Manual 6.3.4. I look forward to discussing this proposal at the December meeting. Best regards, Gil Ohana From: Dave Ringle [mailto:d.ringle@xxxxxxxx]
The draft 05 December 2016 PatCom agenda is located at http://standards.ieee.org/about/sasb/patcom/agenda.pdf ****************************************************************** Panasonic R&D Center Germany GmbH |